FIA recommendations to streamline CFTC regs

September, 2017

FIA responded to the CFTC’s call for suggestions on simplifying and modernizing CFTC rules via Project KISS today. FIA’s Project KISS response is a single comprehensive letter addressing priority areas where the CFTC can make its regulatory regime more effective and efficient without requiring significant agency resources or resulting in significant costs for market participants.

“FIA and our members appreciate that Chairman Giancarlo and the CFTC are not only willing to evaluate current policies for efficiency and effectiveness, but are also willing to open this process to public comment,” said Walt Lukken, president and CEO of FIA. “Now that we have had a few years to evaluate the effect of the Dodd-Frank Act, we have been able to identify areas where regulations would benefit from simplification, modification, or reconsideration. Our proposals are designed to maximize the Commission’s ability to promote competitive, well-regulated markets while reducing unnecessary burdens on market participants. We look forward to working with the Commission on these issues and commend the agency for the progress it has already made in a number of these areas.”

FIA’s Project KISS response was developed in coordination with members of FIA PTG. The response builds on the association’s Roadmap to Smarter Regulation & Healthier Markets, released in May 2017, which analyzed the current regulatory environment for cleared derivatives and identified areas where rules of federal and global regulators could be streamlined or improved to better serve regulatory goals and market participants.

Issues addressed in the letter include:

  • Tailoring cross-border rules so as to prevent market fragmentation
  • Enhancing the predictability and transparency of enforcement
  • Appropriate position limits
  • Retaining the $8 billion swap dealer de minimis threshold
  • Recordkeeping obligations and duplicative regulatory reporting
  • Coordination among financial regulators on cybersecurity initiatives
  • Ensuring capital rules allow for healthy derivatives markets
  • Considering principles-based alternatives to the proposed Regulation AT

FIA's full recommendations are available here.